Living Between Two Worlds: British, American or Canadian — and Building a Life in Spain?

If you’re an expat in Spain with family, financial or legal ties to the UK, the US, or Canada, you’re not alone — and you’re also in a legal grey area more often than you think.

You might already be asking:

• Can my UK or US prenuptial agreement be enforced in Spain?
• If I pass away, will my British or American will work here, or will Spanish law override it?
• What’s the real implication of buying property as joint owners — is it really “50/50” under Spanish law?
• I’ve got a trust or life insurance in another country — how does that fit into my Spanish estate?
• If I own a house here but my heirs are abroad, will they be able to inherit without problems?

These are the kinds of issues that don’t feel urgent… until they suddenly are.

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We help you prevent legal chaos before it starts.

At Costaluz Lawyers, we work with expats who want peace of mind — people like you, who have made Spain their home but still live with one foot in a different legal system.

Here’s how we help:

Cross-Border Marriage & Property Planning

In many common law countries, couples don’t have a default marital property regime. But Spain does.
This can cause major confusion (and risk) when it comes to property division, divorce, or inheritance — especially if you bought property together.

We help you:

• Validate or adapt foreign prenuptial agreements.
• Draft capitulaciones matrimoniales in Spain, where needed.
• Avoid unintended consequences when buying or owning property together.

Wills and Succession: Avoid Inheritance Nightmares

If you haven’t planned your succession with Spanish law in mind, your heirs might face:

• Long delays.
• High legal fees.
• Unexpected Spanish inheritance taxes.
• Even the invalidity of your foreign will.

We:

• Draft Spanish-compliant wills that respect your wishes.
• Coordinate with UK, US or Canadian wills.
• Advise on professio iuris (choosing the applicable law to your estate).
• Handle probate and inheritance procedures from start to finish.

Trusts, Executors, and Common Law Estate Tools

Spain doesn’t officially recognize trusts, but there are legal ways to interpret and apply them here.

We guide:

• Executors and beneficiaries through probate involving Spanish assets.
• Families handling testamentary or inter vivos trusts that include Spanish property.
• Recognition of letters of administration, grants of probate, or powers of attorney from abroad.

Owning Property the Right Way

Do you and your partner own a house in Spain as joint owners?
That’s fine — but did you know Spain does not recognize the automatic survivorship rules of “joint tenancy” unless you explicitly structure it that way?

We make sure:

• Your ownership reflects your wishes (not just the default Spanish rules).
• You understand what happens if one of you passes away or if you split up.
• Your property passes smoothly to the right person without unexpected taxes or delays.

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Don’t wait for a problem to appear to look for a solution.

Most of the expats we help come to us after something has gone wrong — an inheritance blocked, a will contested, a property claim that gets complicated due to foreign laws.

But you don’t have to be one of them.

Let’s get ahead of the issues, and make sure your life across borders is protected.

We speak your language — and we understand both legal systems.

Reach out for a personalized consultation. We’re here to make your transition between legal worlds as smooth and safe as possible.